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(4) How much gain did petitioners realize from the sale of
real property located at 400 Crow Canyon Drive, Folsom,
California?
(5) Are petitioners liable for the addition to tax for
negligence under Section 6653(a)(1) for 1988?
(6) Are petitioners liable for the addition to tax for
substantial understatement of tax liability under section 6661
for 1988?
(7) Are petitioners liable for the accuracy-related penalty
under section 6662(a) because of negligence or substantial
understatement of income tax for 1989?
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and attached exhibits are
incorporated herein by this reference. Petitioners, Maurice E.
Hodgkins and Barbara J. Hodgkins, resided in Sacramento,
California, at the time they filed their petition. For
convenience we have divided this case by issues.
1. Chancery Court
FINDINGS OF FACT
While petitioners' names are on the marquee, the leading
role in this case was played by petitioner husband's brother,
John Hodgkins (John). They trusted John, and he directed them in
their financial affairs, told them which documents to sign, kept
their books, and supplied the figures for their tax returns. And
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